What’s in the Framework?

In summary, while the suggested process is a step forward, the assessment of ‘visual impact’ - which is ultimately a completely subjective criteria - is too restrictive and is given too much importance in the decision-making process.

The danger is that consideration of ‘visual impact’ will outweigh the goal of facilitating more wind energy development in NSW and reduce the benefits to local communities and to the environment.

Clean Energy Objective

The framework’s purpose of securing the benefits of wind farm development for NSW is not articulated strongly enough.

Because the NSW government does not have a legislated target for the development of renewable energy in the state, the extent to which the Framework needs to deliver projects to meet this target is unclear. This leads to a situation where amenity issues such as ‘visual impact’ can be seen as more important than the bigger goal of building renewable energy to reduce emissions.

We recommend that the document’s Strategic Context restate these benefits, alongside recognition of “impacts on communities”, to properly acknowledge the merits of wind development.

Credit where credit’s due

There are a number of aspects of this framework that represent a clear improvement on the current draft guidelines.

The fact that this Framework is being finalised is a positive step, even if long overdue. Finalisation of the Framework will provide some level of certainty for regional communities, landholders and wind farm developers.

The Framework shifts away from the idea of ‘buffer zones’ between turbines and residences that granted an effective veto over particular turbines to wind farm neighbours.

The framework encourages benefit-sharing and promotes effective community engagement with rural communities. AWA has strongly advocated for these issues for many years and we welcome this focus.

The noise guidelines are broadly in line with those adopted in South Australia. This is a positive development that brings NSW in line with other states.

The issue of health is given the short shrift it deserves. The Framework references the positions of the National Health and Medical Research Council and NSW Health Department that there is no evidence of wind turbines causing adverse impacts on health.

An updated study commissioned by the NSW government accompanies the Framework. It again finds there is no consistent evidence that wind farms decrease property prices.

Visual Impact

The visual impact section of the Framework places unreasonable restrictions on how close turbines can be to residences - in some cases, up to 8km away.

It is not clear that the benefits of an individual turbine in terms of emissions reduction, local economic benefits, etc are sufficiently considered against perceived visual impact.

How the Visual Impact Bulletin works

Around half of the Framework’s 60 pages is devoted to the ‘Visual Impact Bulletin’, which outlines how visual impact will be assessed. This gives you an idea of the weight given to this single aspect of the assessment process.

The requirement to conduct early community consultation around visual impact, while good in theory, is problematic. The developer will be announcing their intention to build a wind farm at a stage when very few details of the project design have been finalised. This uncertainty will be a challenge to handle as wind farm opponents may choose to use this to fight the project by creating community division.

situations where wind turbines are visible in a large proportion of the residence’s field of view. Any turbines out to 8km, in this or any other wind farm, are counted.

Any turbines that fall into these categories are deemed to cause significant visual impact and will be subject to ‘further assessment’. These turbines are not automatically ruled out so this is a step forward from the previous guidelines, but it is not clear how much impact is too much impact.

Developers need to manage this impact, by ‘other design solutions’ such as moving the turbine, providing screening, etc. One option is to negotiate a financial agreement with the neighbour. We welcome the inclusion of this option.

Problems with the Visual Impact Bulletin

Wind turbines are clearly a prominent feature of the landscape but many people - probably the majority - view them as a positive addition to the landscape. Visual impact is a subjective measurement and one that shouldn’t be allowed to overshadow the benefits of wind farm development.

We believe that the focus on visual impact obscures the fact that beyond their visual prominence, wind farms have a very small footprint. In comparison to other possible forms of rural development, wind farms create no dust, no smell, minimal noise and any modifications to the landscape can be easily remediated.

While we acknowledge visual impact does need to be considered and that the Framework does not create ‘arbitrary buffer zones’, we are concerned that these tools overstate the visual impact of wind turbines and the stipulated distances need to be reduced.

The visual magnitude measurements that ‘red-flag’ turbines close to a residence should be eased. For example, a turbine with a 150m tip height at 2km, while prominent, should not be considered unacceptable. By way of comparison, a turbine of any height would be allowed at 1 km from a residence in Victoria and 1.5 km from a residence in Queensland.

The requirement for further assessment of cumulative impacts for wind farms out to 8 kms is excessive. This should be based on the definition of “Near Middleground” in Table 7, which is out to 4 kms.

There needs to be definitive recognition in the Framework of a landholder’s right to install turbines on their land. As many of AWA’s members point out to us, “no one owns the view over my property and I have the right to develop my land for any reasonable use.” Wind farms are a permissible development on rural land. There is no ‘right to a view’.

Under this Framework, wind farm projects are being subjected to additional restrictions that are not applied to other State Significant Developments. The visual amenity of a small number of people would not have a significant influence on other State Significant Developments.

Project Modifications

This framework will apply to any significant modifications to previously approved projects.

Many projects that were approved previously are now applying to increase turbine heights to make use of larger, more efficient technology.

We are concerned that a modified project, even though it may have a smaller number of turbines, will have difficulty meeting the increased stringency of this visual impact assessment.

Any approved project that cannot meet the new framework will be left with specifications for outdated, uncompetitive technology. Project modifications that do meet the Framework may still see of project viability threatened by a significant reduction in the numbers of turbines.

The Renewable Energy Target is highly competitive as projects from all states compete against each other on cost. Tighter visual impact requirements are likely to significantly reduce the number of projects that proceed to construction in the $7 billion NSW wind farm development pipeline .

Community Engagement and Consultation

We welcome the emphasis the framework places on community engagement, consultation and, where appropriate, negotiation of benefit-sharing arrangements with neighbouring landholders. In our experience open and transparent consultation is key to community acceptance of wind farm projects.

At all stages of the development process the community and individuals must have the right to negotiate with developers, but not to veto turbines or projects.

Benefit Sharing

The equitable distribution of financial benefits of wind farms throughout a local community is critical for ongoing community cohesion after a wind farm is built. We see room for improvement on the current model which is based on landholder lease agreements, community enhancement funds and neighbour agreements.

The Framework’s increased emphasis on financial agreements is one that we welcome. However, we note that the approach is for neighbour agreements based on ‘compensation’ for perceived impacts. We would prefer to see a model that takes equitable outcomes as its starting point and provides opportunity for community investment in wind farm projects.

Do you like this?

Showing 2 reactions

Optional email code

Mell hayes commented
2016-11-14 16:22:19 +1100

Id like to know if your organisation has visited those residents whom are against the Jupiter Wind Farm proposal. I in particular would welcome a visit from one of your representatives. They are proposing to locate more than 19 turbines within a 3klm radius of our home. They don’t consider this to be anything of concern, and refuse to discuss with us any resolution until the EIS has been released for exhibition. I welcome green energy however, if you refuse to listen to our concern then how else should we be other than unresponsive to a greener Australia.

Amanda Lopez commented
2016-09-13 05:56:57 +1000

We need renewable energy more than ever. Why do we have to fight so many battles?